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A similar perjurious, false, and misleading statement can be found at p. 20, lines 20–25, p. 21, lines 1-16 of the President's grand jury testimony

The President also provided the following perjurious, false, and misleading testimony regarding his knowledge that the contents of the affidavit were untrue:

Q. And do you remember that Ms. Lewinsky's affidavit said that she had had no sexual relationship with you. Do you remember that?

A. I do.

Q. And do you remember in the deposition that Mr. Bennett asked you about that. This is at the end of the-towards the end of the deposition. And you indicated, he asked you whether the statement that Ms. Lewinsky made in her affidavit was

A. Truthful.

Q.-True. And you indicated that it was absolutely correct.

A. I did. And at the time she made the statement, and indeed to the present day because, as far as I know, she was never deposed since the Judge ruled she would not be permitted to testify in a case the Judge ruled had no merit; that is, this case we're talking about.

I believe at the time she filled out this affidavit, if she believed that the definition of sexual relationship was two people having intercourse, then this is accurate. And I believe that is the definition that most ordinary Americans

would give it. Grand Jury Testimony of President Clinton, 8/17/98, pp. 20–21, H. Doc. 105–311, pp.472–73.

Monica Lewinsky filed an affidavit in the Jones case, in which she denied ever having a sexual relationship with the President. During his deposition in that case, the President affirmed that the statement of Monica Lewinsky in her affidavit denying a sexual relationship was "absolutely true.” Deposition of President Clinton in the case of Jones v. Clinton, 1/17/98, p. 204. Monica Lewinsky has stated that she is “100 percent sure” that the President suggested she might want to sign an affidavit to avoid testifying in the case of Jones v. Clinton. 8719/98 OIC interview of Monica Lewinsky, pp. 4-5, H. Doc. 105–311, pp. 1558-9, see also Grand Jury Testimony of Monica Lewinsky, 8/6/98, pp. 123–24, H. Doc. 105-311, pp. 83444. President Clinton told this Committee he believed he told Ms. Lewinsky "other witnesses had executed affidavits, and there was a chance they would not have to testify.” Request for Admission number 18. The President gave the following testimony before the grand jury “And did I hope she'd be able to get out of testifying on an affidavit? Absolutely. Did I want her to execute a false affidavit? No I did not.” Grand Jury Testimony of President Clinton, 8/17/98, p. 119, H. Doc. 105–311, p. 571.

This testimony is false and misleading because it is not possible that Monica Lewinsky could have filed a full and truthful affidavit, i.e. an affidavit acknowledging a sexual relationship with the President, that would have helped her to avoid a deposition in the Jones case. The attorneys for Paula Jones were seeking evidence of sexual relationships the President may have had with other state or federal employees. Such information is often deemed relevant in sexual harassment lawsuits to help prove the underlying claim of the Plaintiff and Judge Susan Weber Wright ruled that Paula Jones was entitled to this information for purposes of discovery. Consequently, if Monica Lewinsky acknowledged a sexual relationship with the President in her affidavit, then she certainly could not have avoided a deposition. The President had to be aware of this and this renders his grand jury testimony on this subject false and misleading.

c. The President made false and misleading statements before

the grand jury when he recited a false account of the facts regarding his interactions with Monica Lewinsky to Betty Currie, a potential witness in the federal civil

rights action brought against him The President provided the following perjurious, false and misleading testimony concerning the false account he provided to Betty Currie regarding his relationship with Ms. Lewinsky:

Q. What was your purpose in making these statements to Miss Currie, if they weren't for the purpose to try to suggest to her if ever asked?

A. Now, Mr. Bittman, I told you, the only thing I remember is when all the stuff blew up, I was trying to fig

ure out what the facts were. I was trying to remember. Grand Jury Testimony of President Clinton, 8/17/98, p. 138–39, H. Doc. 105–311, pp. 590–91.

For very similar perjurious, false and misleading grand jury testimony of President Clinton, see p. 54, lines 19–25, p. 55, lines 125 and p. 56, lines 1-16; p. 130, lines 18–25, p. 131, lines 1–14; p. 141, lines 7-12 and 23–25, p. 142, lines 1–3.

The record reflects that President Clinton attempted to influence the testimony of Betty Currie, his personal secretary, by coaching her to recite inaccurate answers to possible questions that might be asked of her if called to testify in the Paula Jones case. The President did this shortly after he had been deposed in the case.

In his grand jury testimony and responses to the Committee's Requests for Admission, the President was occasionally evasive and vague on this point. He stated that on January 18, 1998, he met with Ms. Currie and “* * * asked her certain questions, in an effort to get as much information as quickly as I could and made certain statements, although I do not remember exactly what I said." Grand Jury Testimony of President Clinton, 8/17/98, H. Doc. 105– 311, p. 508; Response of President Clinton to Question No. 52 of the Committee's Requests for Admission. The President added that he urged Ms. Currie to "tell the truth” after learning that the Office of Independent Counsel (OIC) might subpoena her to testify. (Id at p. 591.)

The President also stated that he could not recall how many times he had talked to Ms. Currie or when, in response to OIC questioning on the subject of a similar meeting that took place on or about January 20 or 21, 1998. He claimed that by asking questions of Ms. Currie he was only attempting to "* * * ascertain what the facts were, trying to ascertain what Betty's perception was.” Grand Jury Testimony of President Clinton, 8/17/98, H. Doc. 105–311, pp. 592–93; Response of President Clinton to Question No. 53 of the Committee's Requests for Admission.

While testifying before the grand jury, Ms. Currie was more precise in her recollection of the two meetings. An OIC attorney asked her if the President had made a series of leading statements or questions that were similar to the following:

You were always there when she (Monica Lewinsky) was
there, right? We were never really alone.”

You could see hear and hear everything.
Monica came on to me, and I never touched her, right?

She wanted to have sex with me and I couldn't do that. In her testimony Ms. Currie indicated that the President's remarks were "more like statements than questions." Based on his demeanor and the manner in which he asked the questions, she concluded that the President wanted her to agree with him. Ms. Currie thought that the President was attempting to gauge her reaction, and appeared concerned. OIC_Referral, H. Doc. 105–3 10, pp. 191-92; Grand Jury Testimony of Betty Currie, 1/27/98, pp. 7176, H. Doc. 105–316, pp. 559–60.

Ms. Currie also acknowledged that while she indicated to the President that she agreed with him, in fact she knew that, at times, he was alone with Ms. Lewinsky and that she could not or did not hear or see the two of them while they were alone.

As to their subsequent meeting on January 20 or 21, 1998, Ms. Currie stated that it was sort of a recapitulation of what we had talked about on Sunday (January 18, 19981... Grand Jury Testimony of Betty Currie, 1/27/98, p. 81, H. Doc. 105–316, p. 561.

d. The President made perjurious, false and misleading state

ments before the grand jury concerning statements he made to aides regarding his relationship with Monica

Lewinsky The President gave the following perjurious testimony under oath before the grand jury:

Q. Did you deny to them or not, Mr. President?

A. Let me finish. So, what I did not want to mislead
my friends but I want to define language where I can say
that. I also, frankly, do not want to turn any of them into
witnesses, because I-and, sure enough, they all became

Q. Well you knew they might be
A. And so
Q. Witnesses, didn't you?

A. And so I said to them things that were true about
this relationship. That I used—in the language I used, I
said, there is nothing go on between us. That was true. I
said, I have not had sex with her as I defined it. That was
true. And did I hope that I would never have to be here
on this day giving this testimony? Of course. But I also
didn't want to do anything to complicate this matter fur-

ther. So, I said things that were true. They may have been
misleading, and if they were, I have to take responsibility

for it, and I'm sorry. Grand Jury Testimony of President Clinton 8/17/98, p. 105–106, H. Doc. 105–311 p. 557-558.

Another perjurious, false and misleading statement by the President regarding conversations with his aides is recorded on p. 100, lines 20-25 of the grand jury transcript.

The following grand jury testimony of several Presidential aides demonstrates that the President's testimony that he "said things that were true” to his aides is clearly perjurious, false and misleading.

The record reflects that President Clinton met with a total of five aides who would later be called to testify before the grand jury shortly after the President's deposition in the Paula Jones case and following a Washington Post story, published on January 21, 1998, which detailed the relationship between the President and Monica Lewinsky. During the meetings the President made untrue statements to his aides:

Sidney Blumenthal Testifying before the grand jury on June 4, 1998, Sidney Blumenthal, an Assistant to the President, related the following discussion he had with the President on January 21, 1998:

He said Dick Morris had called him that day and he said Dick had told him that Nixon-he had read the newspaper and he said "You know, Nixon could have survived if he had gone on television and given an address and said everything he had done wrong and got it all out in the beginning."

And I said to the President, "What have you done wrong?" And he said, “Nothing, I haven't done anything wrong.” I said, “Well then, that's one of the stupidest things I've ever heard. Why would you do that if you've done nothing wrong?'

And it was at that point that he gave his account of what had happened to me and he said that Monica—and it came very fast. He said, “Monica Lewinsky came at me and made a sexual demand on me.” He rebuffed her. He said, I've gone down that road before, I've caused pain for

a lot of people and I'm not going to do that again.” Grand Jury Testimony of Sidney Blumenthal, 6–4–98, p. 49, H. Doc. 105–316, p. 185.

John Podesta In his grand jury testimony on June 16, 1998, then White House Deputy Chief of Staff John Podesta (now Chief of Staff) testified to the following regarding a January 21, 1998 meeting with President Clinton:

A. And we went in to see the President.
Q. Who's we?
A. Mr. Bowles, myself and Ms. Matthews.

Q. Okay. Tell us about that.

A. And we started off the meeting—we didn't-I don't think we said anything, and I think the President directed this specifically to Mr. Bowles. He said, “Erskine, I want you to know that this story is not true.

Q. What else did he say?

A. He said that—that he had not had a sexual relation

ship with her, and that he never asked anybody to lie. Grand Jury Testimony of John Podesta, 6/16/98, p. 85, H. Doc. 105–316, p. 3310.

Erskine Bowles had the following recollection of the same meeting:

A. And this was the day this huge story breaks. And the three of us walk in together-Sylvia Matthews, John Podesta and me-into the oval office, and the President was standing behind his desk.

Q. About what time of day is this?

A. This is approximately 9:00 in the morning or something—you know, in that area. And he looked up at us and he said the same thing he said to the American people. He said, I want you to know I did not have sexual relationships with this woman Monica Lewinsky. I did not ask anybody to lie. And when the facts come out, you'll under

stand. Grand Jury Testimony of Erskine Bowles, 4/2/98, pp. 83–84, H. Doc. 105-316, p. 239.

The record indicates the President also had a January 23, 1998, conversation with John Podesta, in which you stated that you had never had an affair with Monica Lewinsky?

A. See, we were getting ready to do the State of the
Union prep and he was working on the state of the union
draft back in his study. I went back there to just to kind
of get him going—this is the first thing in the morning-
you know, we sort of get engaged. I asked him how he was
doing, and he said he was working on this draft, and he
said to me that he had never had sex with her, and that-
he never asked you know, he repeated the denial, but he
was extremely explicit in saying he never had sex with

Q. How do you mean?
A. Just what I said.

Q. Okay. Not explicit, in the sense that he got more spe-
cific than sex, than the word “sex.”

A. Yes, he was more specific than that.
Q. Okay. Share that with us.

A. Well, I think he said he said that—there was some
spate of, you know, what sex acts were counted, and he
said that he had never had sex with her in any way

Q. Okay.
A. That they had not had oral sex.

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